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Four Tiers of Loss Limitations: A Guide to the New Rules for Pass-through Entities - VIRTUAL

Overview

Owners of S corporations and partnerships are subject to numerous limitations on pass-through losses, each with unique rules, applications, and complexities. With the increase in popularity of pass-through business entities, it is essential for CPAs to understand the complexities and interactions of these pass-through loss limitations.

Prerequisites

Basic familiarity with loss allowance rules of pass-through entities

Objectives

  • Analyze how basis in an ownership interest in a pass-through entity is established
  • Discuss how activity of the entity, distributions, and optional adjustments increase or decrease basis
  • Discuss when basis is "at-risk" under section 465, and the resulting loss disallowance and carryforward related to basis that is not at-risk
  • Define passive activities under section 469 and exceptions to the passive loss rules
  • Discuss when and how aggregation of activities should be used to avoid the passive loss rules
  • Analyze new 461(l) created by the Tax Cuts and Jobs Act of 2017 and understand the limitation calculation and resulting carryforward
  • Analyze the hierarchy of the loss limitations with examples of the application of the four tiers of losses and how they interact

Highlights

  • Tier 1: Basis limitations for S corporation shareholders and partners
  • Tier 2: Section 465 at-risk limitations for S corporation shareholders and partners, including the impact of debt, indemnities, guarantees, and shareholder/partner agreements
  • Tier 3: Section 469 passive loss limitations and exceptions to the limitations
  • Tier 4: The new excess business loss limitation of the Tax Cuts and Jobs Act of 2017 (new section 461(l))

Register Now

Materials are generally available 3 days in advance of an event. Once you have downloaded the manual, we are unable to cancel your registration.

Event Code:

FTL41215

4 CPE Credits
Tax: 4 Credits

Registration

Member Price:
$169 $194
Non-member Price:
$219 $244
    Register by December 1st for Early Bird Pricing.

    Registration is open through 12/14.

    Wednesday, December 15th

    8:30am to 12:00pm
    (Check-In 8:00am)

    Add to Calendar

    Instructor

    Charles Borek